PRIVACY POLICY

Elemnta Group Pty Ltd (ACN 623 443 443) trading as ‘Elemnta’ (‘we’, ‘us’, ‘our’ or ‘Elemnta’) is subject to the Privacy Act 1988 (Cth) and the Australian Privacy Principles (Privacy Law). We value transparency and privacy and are committed to protecting the personal information about you that we collect, hold, use and disclose in accordance with the Privacy Law and this platform privacy policy (Privacy Policy).

ABOUT THIS PRIVACY POLICY

This Privacy Policy relates to the use of our software and provision of our services including a platform that connects financial advisers (Financial Adviser/s) with their clients (Client/s) and various applications, interactive tools and modules (Platform) to facilitate the provision of various financial services by Financial Advisers to their Clients (FA Services).

This Privacy Policy notes if your personal information is collected or only held by Elemnta as a Financial Adviser and as a Client and, to the extent it is collected by us (i.e. rather than held on the Platform for use by, and under the control of, Financial Advisers) how it is collected, used and shared/disclosed by Elemnta.

Apart from as expressly stated in the Privacy Policy (or as directed by your Financial Adviser), we do not access, collect, use or disclose any Client personal information held on the Platform which, at all times, remains under the control of your Financial Adviser. As regards what and how your Client personal information is collected, used and/or disclosed by your Financial Adviser, including via the Platform, please refer to your Financial Adviser’s privacy policy.

YOU DON’T HAVE TO PROVIDE YOUR PERSONAL INFORMATION

If you do not wish to provide us or the Platform with your personal information (or have your Financial Adviser upload your Client personal information to the Platform), you do not have to do so or allow your Financial Adviser to do so. However, if you do not it will mean that you, as a Client and/or as a Financial Adviser, will not be able to use the Platform to obtain or provide, as the case may be, the FA Services.

DISCLOSING ANOTHER’S PERSONAL INFORMATION

Financial Advisers must obtain the approval of their Clients to collect and use their Client’s personal information for/in the Platform, including referring their Clients to this Privacy Policy.

Financial Advisers and Clients that upload any information into the Platform must obtain the approval of all third parties whose personal information is uploaded to or used in the Platform by Financial Advisers, including referring them to this Privacy Policy.

HOW WE COLLECT YOUR PERSONAL INFORMATION

When you, as Client or Financial Adviser, register for and use the Platform your personal information is collected by us to enable your use of the Platform.

The main ways we collect your personal information are:

Personal information you provide to us directly: As a Financial Adviser, in order to use the Platform we will ask you to register and provide certain personal information (as detailed below under “Types of Personal Information We Collect”) to us.

As a Client you may upload your personal information to the Platform for the collection, use and disclosure by your Financial Adviser. This personal information is not accessed, collected, used or disclosed by Elemnta, except as expressly noted in this Privacy Policy or as required by your Financial Adviser in relation to support and maintenance of the Platform and, in such cases, it will only be accessed (and not collected) as directed by your Financial Adviser.

Information we collect automatically: We collect some personal information (like your IP address and device type or when we obtain data feeds through our Platform tools) about you automatically when, as a Client or Financial Adviser you use the Platform. We also collect information when you, as a Client or Financial Adviser navigate through our Platform including what pages you looked at and what links you clicked on so that we can continually provide you with the best experience possible.
Information we get from third parties: As a Client, your Financial Adviser may upload your personal information or organise for the importation of your personal information via data feeds to the Platform for their use to provide you with FA Services. As a Client, as noted, while the Platform holds your personal information under the control of your Financial Adviser, Elemnta does not collect, use or disclose Client personal information, except as expressly noted in this Privacy Policy or as requested by your Financial Adviser.

In addition, as a Financial Adviser, we might also collect certain personal information about you from other sources such as publicly available materials or trusted third parties we engage to provide services to us.

TYPES OF PERSONAL INFORMATION WE COLLECT

Financial Advisers: We collect the following personal information about you (FA PI):

name, phone number, address and/or email addresses;
forms submitted by you and your user preferences;
information from third-party sources that may include name, addresses, email addresses, phone number and/or demographic data;
information collected by us through your use of the Platform including internet protocol (IP) addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and clickstream data; and
your feedback, changes of your content or email preferences, responses to surveys or when you email us or communicate with our support team.

Clients: While we do not collect Client personal information, we note that the following personal information about you may be held on the Platform as uploaded to the Platform by and under the control of your Financial Adviser (or it may have been uploaded by you) and used and/or disclosed by your Financial Adviser when using the Platform in order to provide you with FA Services:

financial information that includes details of your personal and financial affairs, needs and objectives to allow for the provision of FA Services;
your Tax File Number;
your health and lifestyle information (i.e. sensitive information) included in an application for insurance if you have requested such as part of the FA Services.

As noted, you should review your Financial Adviser’s privacy policy to confirm what personal information they collect and how (including via the Platform) they use and/or disclose your personal information.

Clients and Financial Advisers: Elemnta and its marketing and development partners, affiliates and analytics or third-party service providers, such as online customer support providers and email marketing systems, use technologies such as cookies, beacons, tags and scripts. These technologies are used in analysing trends, administering the Platform, tracking users’ movements around the Platform and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies from these companies on an individual or aggregated basis.

We use various user experience tracking tools including but not limited to: Google Analytics Advertising products such as Remarketing with Google Analytics, and Google Analytics Demographics and Interest Reporting. Google Analytics collects data about our Software traffic via Google Advertising cookies and anonymous identifiers. Data collected via these Google products is not linked with any personally identifiable information you submit while using our Platform. If you wish to opt out of the Google Analytics data collection, you may do so on Google’s Software at https://tools.google.com/dlpage/gaoptout/.

We also use cookies for authentication purposes and for tailoring the Platform according to user preferences. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use the Platform but your ability to use some features or areas of the Platform may be limited.

SENSITIVE INFORMATION

By using the FA Services of your Financial Adviser you consent to our holding (in the Platform) your sensitive information referred to in this Privacy Policy for the purposes, uses and to be disclosed as specified in this Privacy Policy.

WHAT WE DO WITH YOUR PERSONAL INFORMATION (THE PURPOSES FOR COLLECTION)

Financial Advisers: We use your FA PI to:

register you and enable your use of the Platform and provide you with information on other services we think will be of interest to you;
facilitate your provision of FA Services to your Clients;
communicate with you by a variety of means including, but not limited to, by telephone, email, SMS or mail;
manage, research and develop the Platform and our services, including through data analytics;
administer our business activities and for record keeping;
meet legal, regulatory and compliance obligations; and
investigate any complaints.

Clients: Other than for maintenance and support where specifically requested by your Financial Adviser, using their access to do so and as directed by them, we do not access, collect, use or disclose any Client personal information. However, as noted, our Platform may hold your Client personal information collected by and under the control of your Financial Adviser for use by the Financial Adviser in the Platform to provide the FA Services to you.

MARKETING MATERIAL

Financial Advisers: We may use your FA PI to provide you with materials, promotions and communications from time to time about our services available to you or from other service providers in partnership with us or to invite you to re-engage with our services.

If we use your FA PI to market or promote our Platform or other services to you, you may notify us at any time that you do not wish to receive any further marketing or promotional material by contacting us directly using the details set out in the ‘Contact us’ section below or through the “Unsubscribe” link in our marketing or promotional emails.

DISCLOSURE OF YOUR PERSONAL INFORMATION

Elemnta does not disclose any FA PI, any Client or other personal information held on the Platform, whether or not collected by us, except as expressly noted in this Privacy Policy or any relevant privacy notice, requested to do so by your Financial Advisor or as required or authorised to do so by law.

From time to time, we may disclose your FA PI to our service providers, insurers, professional advisers, agents, suppliers, third party service providers or subcontractors (including outsourced back office (BPO) services) and others that we transact with in the ordinary operation of our business. This includes disclosing your FA PI to our service providers for the purposes of marketing and promotion, user experience research, surveys and support and maintenance but then only for the specific purpose with which they are assisting us.

If there is a change of control in our business or a sale or transfer of business assets we may disclose to a potential purchaser, under an agreement to maintain confidentiality of such, the FA PI and some other personal information we hold about Financial Advisers but this does not include and we will not disclose, any Client personal information which we hold in the Platform on behalf of a Financial Adviser.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

Financial Adviser: You can contact us at any time to request access to or correction of your FA PI and any other personal information about you which we have collected and then hold as Elemnta.

We request that you keep your FA PI up to date on the Platform or inform us of any changes to your FA PI to ensure our records remain accurate and current.

If you wish to access any of your FA PI that you have provided us, please contact us using the details set out in the ‘Contact us’ section below.

If you believe that any of your FA PI held by us is incorrect and you cannot amend such in the Platform then you may request us to amend that FA PI via the details in the ‘Contact us’ section below.

Clients: As a Client, to request access to or to correct your personal information on the Platform you should, at least in the first instance, contact your Financial Adviser. This is because, in the ordinary course, we do not have access a Client’s personal information on the Platform as this is controlled (i.e. collected, used and disclosed) solely by the Financial Adviser.

IF YOU HAVE CONCERNS OR WISH TO MAKE A COMPLAINT

If you have any concerns about how we handle your personal information, believe we have breached the Privacy Law, wish to make a compliant or if you need further information, please contact us via the details noted below under “Contact Us”. You will need to provide us with sufficient detail regarding your complaint and any supporting evidence. We will investigate the issue and determine the steps to be taken to resolve the complaint. We will notify you in writing if we require any additional information and also of the outcome of our investigation.

If you are not happy with the outcome of our investigation, you may complain to the Office of the Australian Information Commissioner by way of their website www.oaic.gov.au or by phone to the hotline 1300 363 992.

However, as a Client, for complaints about how your personal information is being handled by your Financial Adviser, we recommend you refer to your Financial Adviser’s privacy policy.

CONTACT US

You can contact us as follows:

By email at: support@elemnta.com

By phone at: +61 (02) 4400 9888

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in how we handle personal information and to reflect any changes to the privacy law. If we make changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our website with a notice on our website that the Privacy Policy has been updated.

If required by law or where there are significant revisions to our processing of your personal information, we will also notify you directly of the changes, such as via email or another manner through the Platform. Any such modifications to this Privacy Policy will be effective on our posting the modified version (or as otherwise indicated at the time of posting) and, in all cases, your continued use of the Platform after the effective date of the modified Privacy Policy indicates your acceptance of that modified Privacy Policy.